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Michael Gadd

Michael Gadd. Manager, Continued Airworthiness. The Regulatory Framework. There has to be a recognition that there are primarily two distinct regulatory frameworks at play - FAA under the CFR 14 provisions (US Federal law) - EASA under the provision of EU Regulations

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Michael Gadd

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  1. Michael Gadd Manager, Continued Airworthiness

  2. The Regulatory Framework • There has to be a recognition that there are primarily two distinct regulatory frameworks at play • - FAA under the CFR 14 provisions (US Federal law) • - EASA under the provision of EU Regulations • There is every intention with moving towards greater alignment between the two systems via harmonisation of the technical requirements but this will take time • Establishment of the EU/US Bilateral Aviation Safety Agreement • - 1 May 2011 • - An important step in this harmonisation process • - Not mutual recognition but … • - Greater recognition of each other’s system

  3. EU – US Bilateral Agreement • Annex 1 appendix – Airworthiness & Environmental Certification – • Products & Associated Export Documentation Accepted for Import into EU: • “The following new parts manufactured under U.S. production approval that conform to EASA-approved design data and are eligible for installation in a product or appliance which has been granted an EASA design approval(accompanied by an FAA Form 8130-3, Authorised Release Certificate):….….PMA replacement and modification parts as defined in the technical implementation procedures when accompanied by an FAA Form 8130-3 with appropriate certifying statements.” • http://easa.europa.eu/rulemaking/international-cooperation-bilateral-agreements.php

  4. The EASA – FAA Technical Implementation Procedures • Section 5: Export Airworthiness certificationPara 5.1.8: New Modification, Replacement & Standard Parts – • (a) An Airworthiness Authority, when importing new U.S, modification and replacement parts …, shall accept an FAA Authorised Release Certificate … only when the FAA certifies, by the issuance of the FAA 8130-3 signed on the left side, that each part: • (1)  Is eligible for installation in a product or appliance which has been granted an EASA design approval; • (2)   Conform to design data approved by EASA and is safe for installation; • (3)   Is marked in accordance with para 5.5.2(a) of these Implementation Procedures; and • (4)   Meets all additional requirements prescribed by EASA, as notified • AND …

  5. The EASA – FAA Technical Implementation Procedures • Section 5: Export Airworthiness certificationPara 5.1.8: New Modification, Replacement & Standard Parts – • (b) Additional documentation required for FAA PMA parts: • (1)  For a PMA part that shall be installed on a product which has been certified or validated by EASA, one or more of the following statements should be written in the remarks block of the FAA Form 8130-3, as applicable; • (i)  ”This PMA part is not a critical component.”(ii)  “Produced by the holder of the EASA STC number [INSERT EASA REFERENCE]”(iii) “Produced under licensing agreement from the holder of [INSERT TC or STC NUMBER].

  6. Definition of “critical components” • TIP Para 1.6(i): • “a part identified as critical by the design approval holder during the type validation process, or otherwise by the exporting authority. Typically, such components include parts for which a replacement time, inspection interval, or related procedure is specified in the Airworthiness Limitations section or certification maintenance requirements of the manufacturer’s maintenance manual or Instructions for Continued Airworthiness.” • But also …

  7. For Engines, Propellers & APU: • (CS-E.510(c)/CS-P.150(c) & .160/CS-APU.210(c) & .150) • It is recognised that the probability of Primary Failures of certain single elements cannot be sensibly estimated in numerical terms. If the Failure of such elements is likely to result in Hazardous Engine Effects, reliance must be placed on meeting the prescribed integrity specifications of CS-E 515 (Engine critical parts) in order to support the objective of an Extremely Remote probability of Failure. • For Rotorcraft: • (CS-27/CS-29/CS-VLR. 602(a)) • A critical part is a part, the failure of which could have a catastrophic effect upon the rotorcraft, and for which critical characteristics have been identified which must be controlled to ensure the required level of integrity. • http://easa.europa.eu/rulemaking/faq/commission-regulation-1702-2003-initial-airworthiness.php

  8. The Airworthiness Issues • Main issue is incorrect or incomplete information on the 8130-3(non-compliance with above requirements) • This means a lack of clarity of the validity and acceptability of the airworthiness standard of the part. • This results in challenges to prove acceptability of installed parts or requires their replacement with demonstrable items and can delay a return to service or force the grounding of an aircraft until satisfactorily addressed.

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